Comparability of an international transaction with an ...
Assessing International Transaction Comparability: Key Factors Include Property Characteristics, Functions, Assets, and Risks Involved.
February 25, 2019
Case Laws Income Tax AT
Comparability of an international transaction with an uncontrolled transaction shall be judged with (a) the specific characteristics of the property transferred or services provided in either transaction; (b) the functions performed, taking into account assets employed or to be employed and the risks assumed, by the respective parties to the transactions.
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